Anti-Slavery and Human Trafficking Policy
Irongate Group Ltd and Ram Print Ltd, hereby referred to as ‘the Company’ not only employ individuals directly, but also maintain relationships with many different organisations in its supply chain and customer base. This statement and policy is made pursuant to Section 54(1) of the Modern Slavery Act 2015 (‘the Act’) and sets out Irongate (the ‘Company’s’) actions to understand all potential modern slavery and human trafficking risks related to our business, to what extent measures already exist, and what further measures may be required to prevent slavery and human trafficking taking place in any part of our business or in our supply chains.
We all have a responsibility to be alert to the risks of slavery and human trafficking, however small in our business and in the wider supply chain. As the leading business services provider in the Midlands Irongate recognises that it has a responsibility to take a robust approach to modern slavery and human trafficking, and is committed to preventing any such activity within the business or its supply chains.
Irongates attitude to Modern Slavery is ZERO TOLERANCE. We are committed to opposing modern slavery in all its forms and preventing it by whatever means we can. Modern slavery encompasses (but is not limited to) slavery, servitude, human trafficking and forced labour. We demand all who work for us, and all who have, or seek to have, a business relationship with the Company and/or any member of our Group to familiarise themselves with our Anti-Slavery and Human Trafficking Policy, and to act at all times in a way which is consistent with our tolerance and values.
2.0 The Company
Originally established in 1977 as a retail shop selling photocopying services on Irongate in Derby, we now have a turnover in excess of £19m. Our Head Office is based in Derby and we are the leading business services provider in the Midlands.
Our main categories of provision are:
• Irongate Office
• Irongate Communications
• Irongate Interiors
• Irongate Workwear
• Irongate Facilities
• Irongate Promotions
3.0 Purpose of this Policy
Modern Slavery is a criminal offence under the Modern Slavery Act 2015. We will not tolerate the deprivation of a person’s being by another in order to exploit them for personal or commercial gain. As a leading business services provider, we always work to the highest professional standards and comply with all laws, regulations, legislation, rules and best practice relevant to our business and operations.
We are committed to acting ethically and with integrity in all of our business operations and relationships, whether through direct employment, with suppliers or with contractors, and we are committed to implementing and enforcing measures, processes and controls to ensure that modern slavery is not occurring anywhere in our own business or those of our suppliers or contractors.
This policy sets out our risk and identification processes and the measures and controls which we are and will be taking to effectively implement our zero tolerance commitment.
4.0 Processes for the Prevention of Modern Slavery
The majority of our recruitment is done directly, through our own HR Department and departmental / hiring managers. We do on occasion supplement our own recruitment with agency support where necessary, but this is purely in the introduction of candidates, all interviewing, assessing and screening is conducted in house and in the same way as direct recruitment. We operate a robust recruitment process, including conducting thorough Right to Work checks for all employees to safeguard them against human trafficking or being forced to work against their will.
4.2 Supply Chains
Across all of our categories, Irongate has over 184 suppliers. Some of our suppliers are European or International organisations with whom we have collaborative and open relationships. At present we are not aware of any of our current suppliers or contractors using or being involved in modern slavery. We are committed to ensuring that there is complete transparency in our organisation and in our approach to tackling modern slavery throughout our supply chains. We expect all of our suppliers, contractors and those with whom we have a business relationship to work to the same high standards and zero tolerance. We are currently in the process of developing and establishing new contracting and supplier processes which include specific prohibition against the use of modern slavery, whether adults or children. In turn we expect our suppliers to ensure such tolerance and standards are implemented and maintained by their own suppliers.
Whilst we do not believe that at present we have any activities within the organisation which are considered to be at high risk of slavery or human trafficking, we are working to ensure that we have transparency within our supply chain, and are currently in the process of mapping our supply chain in order to minimise the possibility of modern slavery occurring within our supply chains / contractors.
We will be undertaking the following measures:
1. Conduct risk assessments to establish the areas of our business and supply chains which are most at risk of modern slavery;
2. Communicate and ensure that all our suppliers and contractors understand and are committed to our Anti-Slavery and Human Trafficking Policy, and work to uphold our strong values;
3. Understand the steps they have taken to eradicate modern slavery within their business;
4. Develop and implement specific screening processes for suppliers/contractors before commencing business relationships;
5. Develop contracts with suppliers and contractors which enable us to audit and scrutinise activities and their own supplier relationships in order to satisfy our commitment to anti-slavery;
6. We may terminate the contract at any time should any instances of modern slavery come to light;
7. With regard to European or International suppliers we will establish a UK point of contact, and we expect these contacts to have suitable anti-slavery and human trafficking policies and processes in place.
The Company’s Anti-Slavery and Human Trafficking Policy will be communicated across the organisation and all employees will sign for acknowledgement and understanding of the Policy. The Policy will be communicated further in team meetings and included in the Employee Handbook issued to all new starters with effect from 1 April 2017.
Departmental Managers and Team Leaders are responsible for ensuring that all those who report to them are familiar with, understand and comply with the Anti-Slavery and Human Trafficking Policy and are given refresher training as and when required.
5.0 Responsibility for the Policy
Ultimate responsibility for the commitment and prevention of modern slavery sits with the Board of Directors, who have overall responsibility for ensuring this policy and its implementation comply with legal and ethical obligations. This policy will be reviewed on an annual basis, at the end of each financial year.
6.0 Reporting Modern Slavery or Human Trafficking
The Company has a specific Whistleblowing Policy which provides guidance on how to raise concerns, whether these be in relation to employees, suppliers, contractors or those seeking to establish a business relationship with us. The Whistleblowing Policy is available within the Employee Handbook or on the HR pages of the Company intranet. Individuals are encouraged to raise concerns internally to one of the Whistleblowing Officers; Adam Noble, Sarah Wilson or James Allerton.
We recognise that some individuals may not feel able to raise concerns internally. Public Concern at Work (Independent Whistleblowing Charity) provides a confidential helpline on telephone: 020 7404 6609, email: firstname.lastname@example.org, website: www.pcaw.co.uk
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